A German sunscreen manufacturer received credible evidence from a whistleblower that a senior sales representative for the Mediterranean region was in receipt of secret payments from a Spanish supermarket chain. In exchange, he agreed to cheaper purchase prices for sun protection products, according to the anonymous source.



The company lawyers engaged REMARKABLE Forensics to gather evidence to investigate the allegations. The knowledge gained was to be used in employment law proceedings against the employee. In addition, the company wanted assurances that no other employees were involved in the corrupt behaviour.

Legal action against the supermarket chain or its representatives was also to be considered depending on the findings of the investigation.



Analysis of the senior employee's communication data revealed that he did not act alone, but operated the system with other customers in France, Italy, Greece, Turkey and Egypt involving other employees subordinate to him.

Through predictive coding, the executive employee's emails quickly exposed a coded language, used exclusively between the participants of the scheme. However, the true extent of the corruption was hard to determine. Many terabytes of data produced by the allegedly corrupt unit (over the previous 10 years) had to be backed up and analyzed. This also included deleted data that was laboriously restored.

In this way, it was found that kickback payments had been paid by customers to sales reps for at least 8 years. It appeared that a 'consultancy firm' in Malta had been used for this purpose, run by a trustee.

Further investigations in databases and registers, as well as the questioning of confidential sources, finally resulted in a connection of the Maltese company to organisations in Germany, Switzerland and Belgium.

The companies were controlled by the wives and children of the parties involved.



The corrupt employees were removed from the company, and comprehensive precautions were put in place to rule out any repeat of the situation. In addition, the corrupt entity paid the company heavy contractual penalties, which included the majority of the unlawfully obtained assets. Insights into this were gained through asset research commissioned in parallel to the main forensic investigation.

Business relationships with the fraudulent customers were either terminated, or continued in a modified form, after payment of high settlement payments.

There were no public prosecutions or press reports regarding the alleged corruption.